Privacy Policy

The purpose of this Privacy Policy is to inform you of how Simplicity Coy LLP. (referred to herein as "Simplicity Coy", "us", "we" or "our") manages your Personal Data. This Privacy Policy outlines our policy and responsibility in relation to the collection, use and disclosure of your Personal Data, in order to provide you with an efficient and user-friendly experience in finding the best user experience for you on our web site – www.simplicitycoy.com (referred to herein as “the Website”, “our Website” or “simplicitycoy.com”).

This Privacy Policy is drafted in accordance with the Personal Data Protection Act 2012 (“the Act”). 

By using our Website and services, you agree and consent to Simplicity Coy collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to Simplicity Coy’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

1. Your Personal Data

1.1 In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access to. 

Examples of such Personal Data that you may provide to us include:

(a) your name, NRIC, passport or other identification number, telephone number(s), birthday, mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

(b) information about your use of Simplicity Coy’s website and services, including cookies, IP address and membership details, but only to the extent that Simplicity Coy may identify you from such information;

(c) information about your usage of and interaction with our website and/or services including types of computer/mobile devices and connection information, applications information, bandwidth, statistics on page views, and traffic to and from our website.

2. Collection of Personal Data

2.1 Generally, Simplicity Coy collects your Personal Data in the following ways:

(a) when you register an account with us on the Website using your email address;

(b) when you submit queries, reviews, request for information, online forms relating to any of our content or services

(c) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;

(d) when you interact with our customer service officers, either via online (e.g. web) or offline (e.g. phone, personal contact) means;

(e) when you subscribe to our mailing list;

(f) when you respond to our promotions and other initiatives;

(g) when we receive references from business partners and third parties, for example, where you have been referred by them;

(h) when you submit your Personal Data to us for any other reason.

2.2 When you browse the content or use any services on our Website, either anonymously (without login) or as a login user, we may collect and analyse anonymised information from which individuals cannot be identified (“Aggregate Information”). Examples of such Aggregate Information include, e.g. number of users and their frequency of use, the number of page views (or page impressions) that occur on the Website, and common entry and exit points into the Website etc.

2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

3. Purpose for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, Simplicity Coy collects, uses and discloses your Personal Data for the following purposes

(a) verifying your identity;

(b) responding to your queries, requests, feedback, reviews and/or complaints;

(c) facilitating communications and/or business transactions between Simplicity Coy and our business partners and any third party;

(d) providing services, products and benefits to you, either to our customers generally, or of particular products and services which may be of interest to you;

(f)  conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes;

(g) managing the business operations of Simplicity Coy and complying with internal policies and procedures;

(h) matching Personal Data held with other data collected from other sources (including third parties), for any of the purposes listed herein;

(i) preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;

(j) protecting and enforcing our contractual and legal rights and obligations;

(k) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks; and/or

(l) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.

3.4   If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Simplicity Coy may contact you using such Singapore telephone number(s) (including via voice calls, sms, fax or other means) with information about our products and services (including discounts and special offers).

3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

4.1 Simplicity Coy will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

(a) Simplicity Coy affiliates;

(b) agents, contractors or third party service providers who provide operational services to Simplicity Coy , such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to Simplicity Coy ;

(c) vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on Simplicity Coy ’s sites, whether in conjunction with us or not;

(d) external business and charity partners in relation to corporate promotional events;

(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;

(g) anyone to whom we transfer or may transfer our rights and duties;

(h) banks, credit card companies and their respective service providers;

(i) our professional advisors such as our auditors and lawyers;

(j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

(k)  any other party to whom you authorise us to disclose your personal data

5. Use of Cookies and Other Analytics Codes

5.1 In order to improve user experience on this Website, we may use "cookies" which are small amounts of information placed and stored on your device (e.g. computer or mobile phone). Such cookies will enable us to retain information about your preferences, thereby allowing easier interaction during subsequent use. You may choose to set your browser not to accept cookies, but doing so may prevent the browser from accessing certain content or services of this Website.

5.2 Simplicity Coy may use software, codes or services of Third Party Market Research Companies to measure and analyse the Internet usage across Simplicity Coy’s web sites. Pages on Simplicity Coy web sites may contain codes that enable the Third Party Market Research Company to track visitors to our web sites.

5.3 This information is aggregated by the Third Party Market Research Company and provided to Simplicity Coy for the analysis of the usage of Simplicity Coy web sites. Such data may also be accessible by third party media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.

5.4 In order to improve your online experience, Simplicity Coy may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other web sites. Such data is anonymised and will not be linked to your Personal Data and will only be aggregated for statistical analysis.

6. External Links and Third-Party Sites

6.1 Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

7. Withdrawal, Access and Correction of Your Personal Data

7.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact our Support at support@simplicitycoy.com.

7.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to Simplicity Coy on your behalf.

7.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Simplicity Coy  may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with Simplicity Coy and your being in breach of your contractual obligations or undertakings, and Simplicity Coy’s legal rights and remedies in such event are expressly reserved.

8. Retention

8.1 Any Personal Data provided by you will be retained by Simplicity Coy for such a period as is necessary for the purposes set out in this Privacy Policy or as may be deemed necessary by Simplicity Coy or where otherwise required by law.

9. Governing Law

9.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.

10. Changes to Privacy Policy

10.1 Simplicity Coy may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our Website. 

11. Contact Information

Simplicity Coy LLP
Email: support@simplicitycoy.com


Last updated: 25 Feb 2015